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ESTATE OF COMPTON v. C. I. R.

No. 75-1793.

532 F.2d 1086 (1976)

ESTATE of Ross H. COMPTON, Deceased, by First National Bank of Middletown, Executor, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided April 7, 1976.

Attorney(s) appearing for the Case

William E. Rathman, Middletown, Ohio, for petitioner-appellant.

Scott P. Crampton, Loring W. Post, Asst. Atty. Gen., Tax Div., Dept. of Justice, Washington, D. C., Gilbert E. Andrews, Francis J. Gould, Tax Div., Dept. of Justice, Meade Whitaker, Chief Counsel, Internal Revenue Service, Washington, D. C., for respondent-appellee.

Before CELEBREZZE, PECK and ENGEL, Circuit Judges.

PECK, Circuit Judge.

This appeal challenges a tax court decision upholding the determination of the Commissioner of Internal Revenue that decedent's estate tax return showed a deficiency of $6,992.42.

The facts of the case were largely stipulated. The decedent was employed by Armco Steel Corporation as a project engineer from 1959 until his death on January 17, 1971. As a fringe benefit of this employment, decedent was issued two group term life insurance...

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